How delayed was each auditor’s report?

Here’s the 25-year series (thru FY2018), & the list of auditors. These are the annual general audits of Pacifica Foundation, Inc.; the annual pensions audits aren’t publicly available. Pacifica’s year-end is 30Sep: so fiscal year 1994, FY1994, ends 30Sep1994. [UPDATE: the series now runs thru FY2021.]

Remarks follow, split into two:

Delays – first one, then three

And when are the FY2019 & FY2020 auditor’s reports expected?


The auditors (by FY)

1994-99 Getz, Krycler & Jakubovits (Sherman Oaks, CA)

2000 …. T Curtis & Company (Greenbelt, MD)

2001-07 Ross Wisdom (NYC)

2008-09 PMB Helin Donovan (San Francisco)

2010-11 Ross Wisdom

2012-14 Armanino (San Ramon, CA, then San Francisco)

2015-16 Regalia & Associates (Danville, CA)

2017+ .. Rogers & Company (Vienna, VA)


A Pacifica by-law mandates the directors to ensure that “an annual report” of a financial nature, effectively both a balance sheet & a net income statement, is made public within 120 days of year-end, so by 28Jan:

[t]he Foundation shall cause an annual report to be prepared and furnished to the Board not later than one hundred and twenty (120) days after the close of the Foundation’s fiscal year and, upon payment of reasonable copying costs by the Member, to any Member who requests it in writing, which report shall contain the following information in appropriate detail:

A. The assets and liabilities, including the trust funds, of the Foundation as of the end of the fiscal year;

B. The principal changes in assets and liabilities, including trust funds, during the fiscal year;

C. The revenue or receipts of the Foundation, both unrestricted and restricted to particular purposes, for the fiscal year; and

D. The expenses or disbursements of the Foundation, for both general and restricted purposes, during the fiscal year.

The annual report shall be accompanied by any report thereon of independent accountants, or, if there is no such report, the certificate of an authorized officer of the Foundation that such statement(s) were prepared without audit from the books and records of the Foundation.

Coincidently, ‘within 120 days’ is also required by the Foundation for the Jewish Community, FJC, which agreed on 2Apr2018 to lend Pacifica $3.7m, but with a much stricter term: “audited annual financial statements” (emphasis added). The last time Pacifica had those was for FY2016. [UPDATE: this was rectified with the FY2020 ones.] The relevant clause of the FJC loan agreement:

[s]o long as Borrower is indebted to Lender under the Note and this Agreement is in effect, Borrower shall provide to Lender within one hundred twenty (120) days following the close of each fiscal year of the Borrower, audited financial statements of the Borrower certified by a certified public accountant acceptable to the Lender, each of which financial statements shall be in a form and substance acceptable to Lender and shall include, without limitation, balance sheets, statements of income and statements of fund balances. The Lender shall also be provided with copies of any management letters prepared by the certified public accountant issuing the financial statements promptly upon receipt by Borrower.

Section 6.1, Financial Statements, page 10 (page 11 of the PDF – the section quoted in full),

How often has Pacifica achieved this? Twice in the last 25 years – FY2006 & FY2007, 19Jan & 14Jan respectively. [UPDATE: now 28 years.]

(It’s not publicly recorded how often the cited Pacifica by-law, requiring the public annual financial report, has been complied with.)


.. FY ….. report date ………………………………………….. wait (months) ………………………………………….

1994 … 17Feb1995 ………. 4½

1995 … 17Feb1996 ………. 4½

1996 … 15Feb1997 ………. 4½

1997 … 15Feb1998 ………. 4½

1998 … 28Feb1999 …………. 5

1999 … 28Feb2000 …………. 5

2000 … 10Feb2001 ……… 4⅓

2001 … 15Aug2002 …………………………….. 10½

2002 … 18July2003 ……………………………. 9½

2003 … 12Mar2004 …………. 5½

2004 … 28Feb2005 …………. 5

2005 … 7Feb2006 ………. 4¼

2006 … 19Jan2007 ….. 3⅔

2007 … 14Jan2008 … 3½

2008 … 1Feb2009 ………. 4

2009 … 19Mar2010 ………….. 5⅔

2010 … 26Mar2011 …………….. 6

2011 … 15June2012 …………………….. 8½

2012 … 6Sep2013 …………………………………… 11¼

2013 … 18Mar2015 …………………………………………………………. 17½

2014 … 13Dec2016 ………………………………………………………………………………………………. 26½

2015 … 7Aug2017 ………………………………………………………………………………. 22¼

2016 … 31May2018 …………………………………………………………………….. 20

2017 … 27June2019 ……………………………………………………………………….. 21

2018 … 16July2020 ………………………………………………………………………….. 21½

2019 … 29Apr2021 …………………………………………………………………… 19

2020 … 20Aug2021 ……………………………… 10⅔

2021 … ?10Aug2022 …………………………… 10⅓

. . . Note on the FY2020 auditor’s report

The date of the FY2020 report, 30June2021, is highly misleading: it wasn’t filed until F20Aug2021, per the received stamp on the copy held online by the California Registry of Charitable Trusts, in its Filings & Correspondence section (page 39 of the PDF titled ‘Renewal Filing 2020’, so named because that doc is top of the bundle) – This auditor’s report had an earlier version – importantly with a disclaimer of opinion re the financial statements provided by Pacifica’s accountant, NETA – & Pacifica sent it on 30June, the statutory mandatory deadline, to a non-profits lawyer, for them to check & forward to the Charitable Trusts Section of the California Attorney General’s Office. It never got to the AG: NETA was able to persuade Rogers & Co., the auditors, to accept a much revised pensions liability estimate, which allowed them to judge that the financial statements were materially accurate.

(The altered figures: for the accounting category “[e]stimated late filing penalties, assessments, and interest” used by Pacifica, the report sent to the lawyer gave $547 695 (p. 24; p. 26 of the PDF), & the report filed with the AG gives a mere $8 000 (p. 25; p. 27 of the PDF), a reduction by $539 695. So other figures had to be restated: “[t]otal accrued pension liabilities” fell, but by a lesser amount of $477 917, from $665 557 to $187 640, smaller because it was found necessary, for undisclosed reason(s), to increase the National Office liability by $61 778, from $6 831 to $68 609 (same pages); & the year-end balance sheet was changed, reducing “[a]ccrued expenses and payroll benefits”, & so total liabilities, by $477 918 (so with a rounding), the latter moving from $5 394 241 (the unfiled report, p. 3; p. 5 of the PDF) to $4 916 323 (the filed report, p. 4; p. 6 of the PDF).

So the auditors issued a new report – but Pacifica has no public record that it was seen by either the PNB Audit Cttee or the PNB itself: so, the Cttee didn’t even receive the revised report, let alone accept it, & then pass it on to the PNB. (By contrast, the California Government Code: “[t]he audit committee shall confer with the auditor to satisfy its members that the financial affairs of the corporation are in order, shall review and determine whether to accept the audit, shall [etc., etc.]” (emphases added), § 12586(e)(2) –

These failures, & the missing of a statutory deadline, may be reasons why the AG started an investigation into Pacifica, with a lengthy reply by the Foundation due in mid Oct2021. In keeping with Pacifica being run more as a private club than a public charity, no director or employee has (1) informed the public that filing was made, in violation of law, seven weeks late, (2) informed the public that an AG inquiry is underway, & (3) explained to the public why this is happening. Some of the details & issues are discussed in these posts, 30June & 6July:

. . . Note on the FY2021 auditor’s report

The date, 10Aug2022, warrants a question mark coz although the report indeed bears that date, & was accepted by the Th11Aug PNB, it never seemed to have gone anywhere for a day shy of four weeks – was it altered? did some cash have to be coughed up? Anyway, the delay was never mentioned in an open Pacifica meeting until the W7Sep WBAI Finance Cttee, when being streamed for what may be the first time this century (the wonder of the Pacifica-technology-transparency nexus). Up popped WebPixel Otis, from the cable he’d been nestling in, telling the Cttee, “I’ve just posted it because I was reminded that I hadn’t posted it. Eileen [Rosin, Chair of the PNB Audit Cttee] sent it to me about seven days ago, & I’ve been, you know, ignoring it” (59:43) – And has the doc left PacificaWorld, even though the statutory 30June deadline has been missed? As of Th8Sep there is no record of a filing with the California Registry of Charitable Trusts, the inquirer being greeted with an unambiguous “Awaiting Reporting” – (pump in ‘Pacifica Foundation’). (The links re the two screenshots are time-delimited, & so aren’t live – as dead as . . . a zombie public charity.)

. . . the search page of the CA Registry of Charitable Trusts website – at 8Sep2022, . . .

. . . thru FY2020 the auditor’s reports are there, but not the FY2021 one – at 8Sep2022, . . .


Delays – first one, then three

So, early on, there was a delay, lasting from Oct2001 to July2003, affecting the FY2001 & FY2002 audits. But this was remedied. What’s significant for our purposes, trying to explain Pacifica’s current ongoing travails, is the onset of three later delays: from Oct2011 (the FY2011 audit), from Oct2013 (the FY2013 audit), & from Oct2014 (the FY2014 audit). It remains to be established whether these compounded one another, & how.

These three onsets need to be explained. Was there a delay in completing the record of transactions & intra-Pacifica transfers? A delay in committing to corrective journal entries? A delay in preparing the financial statements presented to the auditors? A delay in assembling the documentary evidence supporting those financial statements? Or were the auditors unavailable to start their work? Was it difficult to provide the auditors with documents, explanations, & justifications? If Pacifica produced an annual report, for the edification (a Lawrence word or a DeWayne word?) of members, staff, listeners, donors, grantors, & others, that might have provided an incentive for the executive director to explain, in an easily found place, what the hell was going on.

So financial administration seems to have started to go ape between Oct2011 & Sep2014. What was different within PacificaWorld during this period? What was making the bookkeeping/accounting side of things start to go haywire? Who was the chief financial officer? Who was executive director? Who was PNB chairperson? Was the Board distracted by battling over motions? How did the Board discuss & address the deficiencies? What actions were proposed, & why did they fail?

Note the financial performance & monetary context:

  • FY2010, the first (of six) ‘there’s a substantial doubt about its ability to continue as a going concern’;
  • Pacifica’s last annual net income was FY2006 (~$1.663m), soon followed by big annual losses: FY2009, ~$2.701m; FY2010, $1.975m (timely auditor’s report, at 26Mar2011); FY2011, $0.564m (slipping, at 15June2012); FY2012, $0.974m (more so, at 6Sep2013); FY2013, $2.824m (gliding, at 18Mar2015); FY2014, $0.771m (dropping into the abyss, at 13Dec2016); & FY2016, $2.031m;
  • grants from the Corporation for Public Broadcasting ended, the last received seem to have been in FY2013 (last CPB disclosure in an auditor’s report is the one, dated 15June2012, for FY2011 (pages 19-20; pp. 22-3 of the PDF)); & this is the latest report Pacifica has had that would meet a mid Aug deadline for the CPB’s Radio Community Service Grant Program, the one with the big bucks; &
  • later developments: 4Oct2017, WBAI tower rent judgement in favour of Empire State Realty Trust (re a near 15-year contract, effective June2005 (FY2005 auditor’s report, p. 16), the responsibility of the signer, Pacifica’s then interim ED, Ambrose Lane, Sr., PNB Chair & WPFW staff-delegate); Dec2017, bankruptcy proposal; Mar2018, $3.085m ESRT settlement (FY2016 auditor’s report, p. 24; p. 26 of the PDF); paid for by 2Apr2018 three-year loan from the Foundation for the Jewish Community, operating as FJC, $3.7m (reduced to $3.265m per PNB decision, 7June2018 –

Is it the case that what occurred Oct2011-Sep2014 lingered, both worsening things over the succeeding years, & making it impossible to take corrective action?

Auditor’s reports at &


And when are the FY2019 & FY2020 auditor’s reports expected?

All done by 30June2021, apparently. That’s according to Jorge Diaz, the principal auditor, of Rogers & Company, playing the M26Oct2020 PNB Audit Cttee:

[t]he ultimate goal really is, um, I think get the fiscal 19 audit done and-and-um-yer perhaps the fiscal 20 audit done by, um, June 30th 2021 […] getting two audits done in one cycle, urgh, but that’s the ultimate goal […] get, get you all up current

26Oct2020 PNB Audit Cttee, 17:32,, here embedded:

Sounds about right. But what I don’t get is why didn’t Jorge make it the summer solstice? Too New Agey, perhaps? It’s really all that hazy, all that vague. Aspirational. Rainbows, unicorns, pink ponies. One for the fairies. No intermediate deadlines disclosed. No necessary phases identified & timed. Nothing serious. And the committeemen & women just sucked & soaked it all up. What’s new?


Intermezzo . . .

. . . really needs to be played given what follows . . .

[UPDATE: this will be largely removed, & made a blogpost.] No-one mentioned a crucial deadline: what may be mid Aug2021, applying for the big bucks disbursed from the Corporation for Public Broadcasting’s Radio Community Service Grant Program, CSG. This annual date keeps changing: 13Aug2020, 24June2019, 11May2018, 12May2017, 16May2016. There’s never much time to apply: the last two application forms were dated the month before, “July 2020” & “May 2019”, with no opening date specified. (That day also didn’t appear on the relevant CPB webpage – however, despite the surprising lack of public disclosure, stations would be informed if they’re on the CPB comms list.) A final point: it’s imperative to remember that the competition is first-come, first-served: “[e]ligible applicants are accepted into the Radio CSG Program in the order their applications were received”. (p. 2)

[UPDATE: note, when the CPB cites a financial year, it refers to when funds are disbursed. That said, the FY2022 Radio CSG came earlier, using the 2016-18 schedule: it opened Apr2021, with a W19May deadline.] [UPDATE: the FY2023 Radio CSG had a similar timing, opening Apr2022, closing Tu24May.] [UPDATE: so the last seven deadlines, 2016-2022, were 16May2016, 12May2017, 11May2018, 24June2019, 13Aug2020, 19May2021, 24May2022 – but remember, the important date is the start date of the application window: as the quote above shows, applications are approved on a first-come, first-served basis.]

The application period is one thing – but deadlines, for that application, start earlier, on 15Feb & 28Feb. (A bit confusing, perhaps, but that’s reality in CPBWorld.) Here’s a description of the CPB cycle, using the example of the FY2022 Radio CSG fund. As noted, when the CPB cites a financial year, it’s referring to when funds are disbursed; & its year-end is that of the federal calendar, 30Sep (& with Pacifica being all-Fed, ditto). The programme applicant is the station, not Pacifica as such. So, the cycle. The FY2020 audited financial statements would be used to fill in the bulk of each station’s FY2020 Annual Financial Report, prepared & sent in during FY2021 (by 28Feb, per Section 15(C) of the programme’s General Provisions and Eligibility Criteria). The application would be submitted in Apr-May2021 (the norm in calendar years 2016 thru 2018). If successful, the station would become a grantee of the FY2022 programme, receiving 70% of the monies in Oct2021 & the balance in Mar2022 (the latter after CPB approval of the Station Activity Survey submitted by 15Feb2022, per Section 15(C)), all to be spent by 30Sep2023. (Given the need for Pacifica to “demonstrate full compliance with the General Provisions at the time of application” (see below), this means that the c. Apr2021 application would have followed meeting the 15Feb2021 SAS deadline.) Given all these strictures, despite the confident way Jorge delivered his prophecy, we have to be prudent & accept that Pacifica will probably have to give that cycle a miss – meaning the earliest it can possibly receive anything is Oct2022. Oh. (Oct2020; this partially describes the FY2021 CSG cycle, per Sections 6(A), 15(A), 15(C), & definition PP, pp. 9, 18, 18 & 28)

There’s one other reason to be prudent amidst the lauding of CPB money as The Saviour: Pacifica has been barred from the CSG, the main programme. Effective 31May2020. Found to be ineligible to even apply. And also “has not completed the corrective actions detailed in CPB’s Management Determination and Required Actions letter dated March 28, 2013”, consequent to the CPB Sep2012 audit report. Given seven years, & still couldn’t remedy. The 22May CPB letter to ED Lydia Brazon & PNB Chair Alex Steinberg detailed two other immediate effects: removal from music licensing agreements negotiated & paid for by CPB “on behalf of public media”; & ordered to return $137 506 within 30 days, the FY2009 & FY2010 overpayment detected by their audit. (not on their public website, but then their security is less than naive; also at; & (oig = Office of the Inspector General; nine audits issued in the fiscal year, including that of Cesar Chavez Foundation KUFW-FM, of Visalia, CA (south-east of Fresno, in the San Joaquin Valley), part of the nine-station Radio Campesina Network, found to have committed some of the same violations as Pacifica –

The CPB helpfully pointed the way back: “[t]o be considered for re-entry to the CSG program, the Radio CSG program must be open to new applicants, Licensee and Stations must demonstrate full compliance with the General Provisions at the time of application, and Licensee and Stations must fulfill all requirements outlined in the March 28, 2013 letter” (emphases added). Good news is that, at least in the 2020 application period, “CPB will accept a limited number of stations into the Radio CSG Program during CPB’s FY 2021 grant year” (FY2021 New Applicant Guidelines, p. 2).

(Also note that a mid Aug2021 application needs Nielsen listening data from spring 2019 & spring 2020 – homologous to “to calculate the Listening Index for FY2021 CSGs, Nielsen Radio’s spring 2018 and spring 2019 AQH must be averaged” (FY2021 Radio Community Service Grants General Provisions and Eligibility Criteria, definition F, p. 24; that’s Apr-May-June average quarter-hour persons, listening for 5mins minimum in the 15mins period). This means the current effort to improve Pacifica programmes can only feed into a possible May/Aug2022 application.)

Furthermore, at the time of application, Pacifica has to be compliant with all requirements of both the Communications Act of 1934 & the CPB – otherwise the application isn’t even looked at, it being stamped ineligible. And currently Pacifica violates both. Multiple times. Here are two egregious topical examples from calendar year 2020, info per meetings archive ( – use the ‘Filter Committees’ search box at top of page):

(1) the mandatory community advisory boards, meeting “at regular intervals” (so not once a decade): KPFA, was last due to meet 22Feb2020, the second listed for the calendar year, but no evidence offered that the CAB met in 2020; KPFK, meetings only scheduled since Oct2020, with no evidence offered that the CAB met in 2020; KPFT, seemingly a success, 10 meetings listed, with three agendas (the other agenda/minutes links go to content that’s not as claimed), but only four online meetings had joining details, with no claim made that these proved accurate, allowing public attendance – indeed, no evidence offered that the CAB met in 2020; WPFW, the only meeting listed was the last Sunday afternoon of the year, 27Dec, albeit with joining details, with no evidence offered that the CAB met in 2020; & WBAI, two meetings listed, Jan & Dec, the links go to content that’s not as claimed, & no evidence offered that the CAB met in 2020; &

(2) the PNB Development Task Force has announced nine public meetings, since 24June, with five cancelled (after all, it’s only trying to identify how to address the contractual need to pay by Th1Apr2021 the $3.265m Pacifica owes the Foundation for the Jewish Community, FJC). Just one small detail: not streamed, & no joining details published, so the public couldn’t attend.

It’s worth explaining that contrary to Pacifica delegates’ folklore, calling something a taskforce or working group or whatever, doesn’t put it beyond the law, allowing it to secrete itself away: they’ve been set up to help, to produce information – in a phrase, they’re an “advisory body”. Yes, there are circumstances permitting “closed sessions”, but otherwise if its proceedings touch on anything to do with “public broadcasting”, & they “may influence the opinions of members” (emphases added), then that “makes it a meeting”, even though those “deliberations do not require any formal action or vote” – and the public have to be able to attend those proceedings. No ifs, no buts. Federal law. ‘Report-outs’ are irrelevant; likewise audiofiles or videos. Attending means as-it’s-happening. Bearing witness to events as they happen.

Validating evidence:

“[f]unds may not be distributed pursuant to this subpart to any public broadcast station (other than any station which is owned and operated by a state, a political or special purpose subdivision of a state or a public agency) unless such station establishes a community advisory board. Any such station shall undertake good faith efforts to assure that (i) its advisory board meets at regular intervals; (ii) the members of its advisory board regularly attend the meetings of the advisory board; and (iii) the composition of its advisory board are reasonably representative of the diverse needs and interests of the communities served by such station” (Communications Act of 1934, § 396(k)(8)(A), pp. 217-8) – embedded at;

“[f]unds may not be distributed […] unless the governing body of any such organization, any committee of such governing body, or any advisory body of any such organization, holds open meetings preceded by reasonable notice to the public” (same doc, § 396(k)(4), p. 216, emphases added);

“[t]he term ‘meeting’ means the deliberations of at least the number of members of a governing or advisory body, or any committee thereof, required to take action on behalf of such body or committee where such deliberations determine or result in the joint conduct or disposition of the governing or advisory body’s business, or the committee’s business, as the case may be, but only to the extent that such deliberations relate to public broadcasting” (same doc, § 397(5), p. 224);

from the current CPB’s compliance guide, “B. Open Meetings: Meetings that must be open to the public include, but are not limited to [re the “any advisory body” specified in the Comms Act cited above], the following (collectively Open Meetings): 1. board meetings; 2. board committee meetings; and 3. community advisory board (CAB) meetings. C. Prerequisites for a ‘Meeting’: In order for a gathering of board, committee, or CAB members to constitute a meeting under the Act, the following are necessary: 1. the presence of a quorum; and 2. deliberations that determine or result in the joint conduct or disposition of business relating to public broadcasting. Note that deliberations do not require any formal action or vote. Any discussion of public broadcasting issues that may influence the opinions of members makes it a meeting” (CPB, Compliance, June2019, § I(B) & (C), p. 2, emphases added) –; &

“[s]tations that certify their compliance but are subsequently found to be non-compliant will be subject to […] a penalty of $5 000 per infraction” (CPB, CSG Non-compliance Policy, Jan2016, p. 1, emphases added) –


Well, to return to Jorge’s prophecy, & the heavy schedule it entails, you’d expect the PNB Audit Cttee to be meeting twice a month, not least to find out what the problems are. But no: since the 14July Cttee’s recommending of the FY2018 report to the PNB, it has met thrice (M26Oct, M9Nov (also had private session – with no public report), & 30Nov), with no cancellations. Inexplicably, the 9Nov meeting had no update on the audit, even though George Walter, NETA Senior Controller, was present – and, in typical PacificaWorld fashion, no-one asked why, & no-one asked George. So no surprise the Cttee didn’t meet in Dec, & no next date has been set. Maybe they’ve stopped meeting. In fact, why not?

Elephant: why has the Cttee ground to a halt? If there’s progress to report to the world, to the members, staff, listeners, & donors/grantors, then have a meeting & spread the news. If the audit is in abeyance, becalmed, then have a meeting, let Chair Eileen it’s Ros-in’ Rosin relate the difficulties, & the assembled can sort out whether they can help, without sticking their oar in, making things worse. But no, Simon & Garfunkel. As another month slips by.

And the latest news, M30Nov?

George Walter, NETA Senior Controller: I’m, urgh – I hope to have a, an updated trial balance, um, that’s gonna be sufficient &, urgh, in good enough shape to, urgh, send to the auditors, um, as a, as – call it a stake in the ground, & that is the trial balance upon which, urgh, we’ll do the audit […]

Chair Eileen: And you’re hoping to have that when, George, when?

George: By the end of the week.


George: I think, urgh, having members of this Cttee, urgh, go into their stations, um, um, I don’t want to say blindly, but, um, urr, challenging, urgh, for, for all these items, urgh, I would find that less than helpful


Anita Sims, Pacifica CFO & NETA Executive Vice President, their #2, responding to Adriana ‘point of point, Madam Chair’ Casenave: Let me first, George, if I may. Um, since, since we have been working with Pacifica, & when we first came in that, urgh, Mr Livingson – Livingston asked me if I would consider taking this job on, quite frankly I had no idea – none whatsoever – how far behind the organization was from a financial perspective, urgh, because chances are I might have [suppressed laughter] turned the job down, quite frankly

30Nov2020 PNB Audit Cttee, 9:21, 40:18, & 49:00,, here embedded:

So now we learn that there isn’t even a FY2019 trial balance. Jesu! Yet we were told five weeks earlier, 26Oct, as cited above, that the audit’s underway, all systems go. Now George says it’s going to take the rest of the week for him to generate the trial balance. No wonder there wasn’t a progress report at the 9Nov meeting. This audit has started out as a PR crock. It hardly needs stirring.

And NETA no wan’ militia rumbling with the station business managers, k.

But that’s the least of it, given that Anita sounds at the end of her tether . . . And the Pacifica wars have hardly begun: she’s seen nothing yet.

All in all, as The Lunatic, the Deplorable-in-Chief, puts it (but never as a combo), it is what it is, we’ll see what happens.


[As a courtesy, for c&p: ½ ⅓ ⅔ ¼ ¾ ⅕ ⅖ ⅗ ⅘ ⅙ ⅚ ⅐ ⅛ ⅜ ⅝ ⅞ ⅑ ⅒]

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